Revisions policy
Errors we fix, of course
Should inaccuracies in the pension administration come to light, it goes without saying that we will do everything possible to rectify them. After all, a member derives his/her rights from the pension regulations.
This may lead to the adjustment of previously communicated amounts of pension entitlements. For whether or not the administrator corrects an erroneous determination of benefits already in payment, the board uses the decision framework below.
If the fund intends to correct an erroneous past pension benefit, a legal test will always be made to determine whether a past correction is permissible
Pension determined too low?
We always correct underdetermined pensions. We correct towards the future and also pay out underpaid pensions in the past.
Pension determined too high?
We correct towards the future and also reclaim past pension overpayments in various situations. Below, we describe the principles for determining whether overpaid pensions will be reclaimed. The board may deviate from these principles.
We reclaim overpaid pensions above €500
If the size of the total financial impact over the period of making the error and discovery is less than €500 in total, the fund will not proceed with correction. The costs associated with the effort of correction, communication, and legal review do not outweigh amounts smaller than €500.
We basically claim back up to 5 years
In the light of adequate management within the pension fund, the relationship between the fund (professional party) and the participant (private individual), it is reasonable to provide protection to the participant with regard to the time period within which errors must be discovered and corrected about the past.
An exception may be made to the above principles if:
- The error on an annual basis exceeds 10% of the benefit or more than €5,000 on an annual basis. In this case, the fund may proceed to recover over a longer period. Within limits, it can be expected that errors of a certain (large) size will also be signalled by the participant. This limit is set in the assessment framework at more than 10% of the benefit or more than €5,000 on an annual basis.
- The size of the error exceeds 25bp of fund assets. In this case, the fund may still recover. An error in determining the amount of a benefit may affect more than one participant. This then creates a cumulative effect that has a noticeable impact on the fund’s financial position and thus affects things like indexation potential. If this is the case, the board has to make a specific consideration in the relevant case between the interests of the “affected” participants and those of the other participants in the fund. This consideration cannot be framed in advance in a decision framework.